IR 05000498/1980038
| ML19350A990 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 01/29/1981 |
| From: | Crossman W, Randy Hall, Tapia J, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19350A988 | List: |
| References | |
| 50-498-80-38, 50-499-80-38, NUDOCS 8103190030 | |
| Download: ML19350A990 (9) | |
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U.S. NUCLEAR RE6..ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-498/80-38, 50-499/80-38 Docket No. 50-498; 50-499 Category A2 Licensee:
Houston Lighting & Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project, Units 1 & 2 Inspection at:
South Texas Project, Matagorda County, Texas Inspection Conducted:
December 15-18, 1980 Inspectors:
w I-29-61 0. P. Tom}tif50n, Reactor Inspector, Engineering Date Support Section (paragraphs 1, 2 & 3)
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I. Tapia, Reactor Inspector, Engineering Date
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Support Section (paragraphs 1, 2 & 3)
Approved by:
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/h W. A. Crossman, Chief, Projects fection
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R. E. Hall, Chief, engineering Support Section Oat.a Inspection Summary:
Inspection on December 15-18, 1980 (Recort No. 50-498/80-38; 50-499/80-38)
Areas Insoected:
Unannounced follow-up inspection of construction activities pertaining to the resumption of AWS welding, re-examination and repair of existing welds, and review of responses to NRC Inspection Report No. 50-498/79-19; 50-499/79-19 findings.
The inspection involved forty-eight inspector-hours by two NRC inspectors.
Results:
No violations or' deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- R. A. Frazar. Manager, Quality Assurance
- L. D. Wilson, droject QA Supervisor
^B. R. Schulte, Civil QA
- C. L. Harvey, QA Quality Systems
- J. Kemper, Construction Supervisor R. A. Carvel, Project QA Supervisor Other Personnel
- R. L. Hand, Project QA Genertl Supervisor, Management Analysis Company (MAC)
- F. G. Miller, Chief Welding ingineer, Brown & Root (B&R)
- D. J. Harris, Manager, Quality Engineering, B&R
- M. D. Muscente, Welding Program Manager, B&R C. Singleton, Civil QC Superintendent, B&R J. Ruud, Supervisor, Civil' Quality Engineering, Management Analysis Corp. (MAC)
The IE inspectors also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.
- Denotes those attending the exit interview.
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Licensee Action on Previous Insoection Findings During this inspection certain corrective actions concerning the findings of Investigation Report No. 50-498/79-19; 50-499/79-19, and additional items extracted from the NRC-transcript of the public meeting with HL&P/
B&R on August 19, 1980, and commitments from management meetings were reviewed:
The following four items related to radiography were individually reviewed, but are being addressed together in this report:
(Closed) infraction (50-498/79-19-A-11a; 50-499/79-19-A-11a); (Closed) infraction (50-498/79-19-A-11b; 50-499/79-19-A-11b); (Closed) Construction Deficiency No.17; (Closed)
Thirteen Point Response, Item 8a.
The IE inspector randomly selected the radiographs for six ECW piping joints inspected after October 6, 1980, for a thorough review.
The purpose of this review was to assure compliance with the ASME Boiler and Pressure Vessel Code requirements.
Selected for this examination w~sre:
ECW-1105 FW-0032, ECW-2102 FW-0012, ECW-2102 FW-0018, ECW-2102 FW-0020, ECW-2302 FW-0010 and ECW-2305 FW-0036.
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were site-welded circumferential joints radiographed 100% as part of the re-examination and repair program, Section 3, issued on September 5, 1980.
A total of fortu-eight radiographs were reviewed for shooting technique, proof of coverage, penetrameter selection and placemert, film densities, film identification, image sensitivity and adequacy of developing tech-nique.
Each film was individually evaluated to Code acceptance standards and the IE results compared to the corresponding interpretation sheets.
For.the sample of film examined all characteristics and evaluations appear'ed to be in compliance with the ASME B&PV Code requirements.
These four items are closed.
(Closed) Public Meeting Commitment H-23.
New forms have been issued for all in process and final inspection which now include sign ture blanks for each inspection performed.
Checks can now be made of imoectors'
qualifications by tracing the names of inspectors back to reco Hs for qualification dates, levels and methods.
This item is closed.
The following six items relating to personnel qualifications were individ-ually reviewed, but are being addressed together in this report:
(Closed)
Public Meeting Commitments A-37, A-39, A-40, A-49, A-56, and A-80.
The task force conducted a review of records of all completed AWS and ASME safety-related welds.
This has been completed and is documented in TRC 5A700GP004-8, dated July 28, 1980.
Some discrepancies were found, but these findings appear to be negated by other commitments to reinspect 100% of the afety-related welds and to conduct retraining and requalifi-cation of all welders and inspectors.
All inspectors and welders currently at South Texas Project have been retrained and requalified.
All new work and work performed as part of the reinspection / repair plan will be done by personnel qualified since September 8, 1980.
Each of the welding and NDE procedures ' as been reviewed and either revised or totally rewritten to incorporate all of the pertinent requirements.
The revision / rewrite included the following welding procedures:
MECP-1, Rev. 14; MECP-2, Revs. 8 and 9; MECP-3, Rev. 3; MECP-4, Revs. 10 and 11; MECP-5, Rev. 1; MECP-8, h >s. 4, 5 and 6; ME.CP-9, Rev. 1; MECP-10, Rev. 2 and MECP-12, Revs. O, 1 and 2.
Also included were the following NDE procedures:
ST-NDEP 2.1, Revs. 10 and 11; ST-NDEP 3.1, Rev. 9; ST-NDEP 4.1, Rev. 9 and ST-NDEP 5.1, Rev. 8.
These procedures include both production and qualification procedures for welding and inspection.
These six items are closed.
The following four items relating to procedures were individually reviewed, but are being addressed together in this report:
(Closed) Public Meeting Commitments H-8, A-47, A-66 and A-67.
A review was made of the PSAR/FSAR and relevant engineering specifications to identify the applicable editions
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and addenda of the specified codes and standards.
All procedures and revisions listed in previous paragraphs have been either revised or rewritten to incorporate the proper and complete requirements.
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i current training and requalification program includes familiarization
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with these new procedures and all welders and inspectors presently
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working at South Texas Project have been qualified in accordance with them.
All repair and new production welding is also being ac omplished in com-
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pliance with these latest revisions.
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These four items are closed.
-The following three items relating to planning commitments were individually
reviewed, but are being addressed together in this report:
(Closed) Public Meeting Commitments H-10, H-25 and A-87.
The schedule of outstanding commitments relative to welding and NDE has been compiled and was delivered to the NRC on September 9,1980, in the form of the following three booklets:
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STP-PGM-12 Welding Program Description, dated September 8, 1980; Attachment
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I, Interim Report, Review of Safety Related Welding, dated July 28, 1980; and Attachment II, Re-examination, Repair and Welding Restart Plans, Rev. 1,
dated September 8, 1980.
These have since been modified by the Twelve-Week AWS Restart P.lan, the Ten-Week ASME Restart Plan and improvements in the ongoing re-examination and repair program for existing welds.
The B&R l
Chief welding engineer has issued four monthly reports, at this time, which
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cite important highlights in the welding program, critical items and prob-lems, manpower summary and other pertinent information items.
These monthly. reports are not routinely forwarded to the NRC but are available upon request.
.These three items are closed.
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The fol. lowing eight items relating to the re-examination and repair program were individually reviewed, but are being addressed together in this report:
,(Closed) Public Meeting'Comaitments H-9, H-25, M-17, M'18, A-34, A-35, A-43 and A-81 The reassessment and verification of safety-related welding has been addressed in the re-examination and repair phase of the restart program and in the Task Force Interim Report TRD-5A700GP004-B, dated August 15, 1980.
In this report, recommendations were made, which were later accepted as commitments, to reinspect:100% of all ASME Class 1, 2, and 3 piping. welds and all ASME NF-piping hanger welds produced to date.
All site produced circumferential welds on the ASME Class 3 ECW piping system will also be radiographed and liquid penetrant inspected 100L
. All AWS welds previously produced will also be visually reinspected 100L
Any.. rejectable indications noted during these reinspections will be repaired'to meet the applicable quality standards.
A schedule for tne repair work was established and presented 'to the NRC in the form of a
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letter to the Regional Director, dated September 10, 1980, and in STP-
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-PGM-12,: Attachment II, for the re-examination, repair and welding restart
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plans.
This schedu'e was further refined by the issuance of three welaing engineering instructions (WEI 5, 6, and 7) along with the Twelve-Week AWS Restart Plan and the Ten-Week ASME Aestart Plan.
All work performed to date under the restart programs has been accomplished under the direct guidance of an independent Level III inspector provided by United States Testing and overchecked by a B&R Level III inspector.
A commitment was made to review all radiographs produced prior to issuance of the Order to Show Cause.
This was accomplished partially by the Task Force and partially by the B&R Level III inspector and was completed prior to July 18, 1980.
The results of this review are documented in Section 1.3 of the Task Force Interim Report TRD-5A700GP004-8 which has been ferwarded to the NRC for review.
These eight items are closed.
The following four items relating to ASME welding were individually reviewed, but are being Oddressed together in this report:
(Closed) Public Meeting Commitments A-43, A-50, A-75 and A-79.
A review of the ASME weld documenta-tion was conduc*.ed by the Task Force and the findings are discussed in Interim Report 1RD-5A700GP004-B, dated August 15, 1980.
The walk-cown of the ASME piping was not conducted as a separate inspection but will be accomplished and documented as a part of the 100% reinspection of all ASME piping welds.
This wi?I be completed when the re-examination and repair of the piping is completed.
The Task Force Level III inspector and the B&R Level III inspecttr did not conduct a review of the radiographs of site produced welds on t:., ASME Class 3 ECW piping as this commitment has been superseded by the decision to radiograph and liquid penetrant inspect each site-welded joint 100% and repair as necessary.
This work is presently in progress on piping spools stored in the lay-down yard.
These four items are closed.
The following five items relating to AWS welding were indivi'ually reviewed, but are being addressed together in this report:
(Closed) Fublic Meeting Commitments A-44, A-45, A-71, A-72 and A-73.
The Task Force conducted a review of all AWS Category 1 shop weld requests, all available QC inspec-tion drawings and all available Examination Checks (EC).
The results were tabulated and are a part of Int <; rim Report TFO-5A700PG004-8, dated August 15, 1980.
Although documentation inconsistencies resulted in a loss of trace-aoility in the inspection of some welds, resolution will be accomplished by the performance of 100% re examination of all AWS Category 1 welas.
This re-examination and repair, as outlined in TAD-5A700PG004-B, Attachment II, and the Twelve-Week AWS Restart program, is being conducted by personnel qualified in accordance with current approved welding and inspection procedures.
All welding and inspect. ion procedures, including those for qualification of ' personnel, have been revised or rewritten since the issuance of the Order to Show Cause to assure compliance with applicaule requirements.
These five items are closed.
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(Closed) Un q:olved Item (50-498/79-19-56; 50-499/79-19-56):
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that a Nonconformance Report (NCR) was written because the intake structure was improperly cured, but no action was taken.
This allegation was reported as being made by Irdividual A9 in Investigation Report No. 50-498/79-19; 50-499/79-19.
A review of the Summary of Statement by Individual A9, reported in Appendix 2 of the Investigation Report, does not reflect this allegation.
A review of siatements made by other Individuals was also unproductive.
Nevertheless, the matter was investigated during this inspection by reviewing all the curing records associated with the etnstruction of the Essential Cooling Pond intake structure (sixty six concrete placements).
In addition, a review of all NCRs generated durir.g the time period enveloping the sixty-six concrete placements was also performeo.
The review of the curing records indicates that all concrete placements were cured in accordance with Pro-ject Specification requirements.
The review of the NCR log also resulted in nothing being found to substantiate the allegation.
Based on the reviews performed during this inspection, the allegation warrants no further review.
This item is closed.
(Closed) Unresolved Item (50-4?S/79-19-59; 50-499/79-1L-59):
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a QC inspector, in a signed sworn statement, indicated that he discovered three horizontal reinforcing bars omitted.
As reported in Investigation c
Report No. 50-498/79-19; 50-499/79-19, the allegation was not fully investigated to ascertain whether there was a FREA (Field Request for Engineering Action) or NCR (Nonconformance Report), or other disposition.
During this inspection, a follow-up interview was held with the QC inspector.
The QC inspector stated that he had discovered three horizontal reinforcing bars ~omitted the day after he had conducted a preliminary inspection at the conclusion of which he told the construction superintendent that everything looked fine.
He related that when he subsequently discovered the missing bars, the superintendent became furious and cursed him and called him a liar.
The QC inspector stated that the three bars were later installed and that the reinforcing steel as placed conformed to the design drawings.
He indicated that when he gave his original statement he was trying to express his displeasure of the way the construction superintendent had respended to his finding, and not any concern with the as-built conditian of the structure.
This item is c'osed.
-(Closed) Public Hearing Commitment H7:
Coordinators from Construction and QA have been assigned to perform planning and performance of the Complex Concrete Restart activities.
(Closed) Public Hearing Commitment H13:
Construction procedures which were reviewed by the IE inspector have been revised in a new format with input from the Construction and QA groups.
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(Closed) Public Hearing Commitment H18:
This office has been provided with a copy of the Dynapac compaction equipment recommendations.
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(Closed) Public Hearing Commitment H19:
Information addressing the settlement of the Unit 2 Mechanical-Electrical Auxiliary Building has been submitted to this office.
This information will be reviewed in conjuction with the final review of Show Cause Order Item (2)(b).
(Closed) Public Hearing Commitment H20:
A copy of the PDCN (Preliminary Document Change Notice) to the backfill TRD (Technical Reference Document),
Revision B was supplied to this office and the CCN (Document Change Notice)
was subsequently issued.
(Closed) Management Meeting Commitment M23:
Sampling by coring in the Unit 1 Reactor Containment Building has been accomplished.
The results of all core samples will be reviewed in conjunction with the final review of Show Cause Order Item (3)(b).
(Closed) Management Meeting Commitment M24:
A status report by the Task Force on concrete verification has been received by this office.
(Closed) Management Meeting Commitment M26:
Testing of the Unit 1 RC8 has been completed.
(Closed) Management Meeting Commitment M29:
Quality Construction Procedure No. A040KPCCP-25 was issued.
It authorizes the QC inspector to stop work in progress until nonconforming conditions are resolved by a Project Site Engineering representative.
This matter was previously addressed in Report No. 50-498/80-24; 50-499/80-24.
(Closed) Show Cause Commitment A22:
Technical Reference Document No.
3A700GP002-B has been reviewed by the IE inspector.
The review of the test fill programs conducted to date has resulted in the closure of Show Cause Order Item V.A.(2)(a), " Provide Information to Address the Test Fill Program Which Established the Soil Conditions, Lift Thickness, Compactive Effort, and Equipment Cha:acteristics Necessary to Develop the Necessary-In p? ace Densities." This review is documented in Inspection Report No. 50-498/80-?4; 50-49s/80-24.
(Closed) Show Cause Commitment A23:
Define depths for in place density testing as a means of assuring Systematic Field Quality Control.
In the closure of Unresolved Item No. 50-498/80-17; 50-499/80-17, in Inspection Report No. 50-498/80-24; 50-499/80-24, the IE inspector reviewed the change' to the structural backfill specification which specifies the criteria for testing of the backfill.
(Closed) Show Cause Commitment A24:
An 0 valuation has been made by the B&R task force to reconfirm the compliance of the Category 1 structural backfill placed at the site'with design basis material characteristics described in FSAR 2.5.4.8.3.
The licensee's response to Show Cause Order Item V.A.(2)(b), " Provide Information to Address the Comparison of Materials Tested and Described in Section 2.5.4.8.3 of the FSAR Addressing
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Liquefaction With Those Used in the Field," was reviewed in Inspection Report No. 50-498/80-24; 50-499/80-24.
That review resulted in closure of the Show Cause Item.
(Closed) Show Cause Commitment A33:
Future inspection activities will be conducted under engineering direction to assure satisfactory inspec-tions supported by comprehensive documentation.
During this inspection, Technical Reference Document No. 3A700GP005-B, " Structural Backfill Con-struction, Engineering and QC Functions," was reviewed and found to define the inspection and testing activities as being under the direction of the Resident Engineer responsible to the Structural Department Project Engineer.
(Closed) Show Cause Commitment A88:
A review of the status report, dated August 15, A980, by the Task Force on concrete verification, has shown which placements were subject to inspection in the Unit 1 Reactor Con-tainment Building.
Further review of the Task Force efforts will occur on receipt of the licensee's final report on the concrete verification program.
(Closed) Show Cause Commitment A89:
The Task Force and Consultants Panel are reviewing the results of previcus HL&P/B&R investigations of the Reactor Containment Building shells.
This information is included in the Task Force status report.
(Closed) Show Cause Commitment A90:
A list of unretolved concerns pre-viously identified in NRC, HL&P and B&R Audits pertaining to the Unit 1 Reactor Containment Building Internals was also addressed in the Task Force status report.
The same review for other buildings will be included in the final Task Force report.
(Closed) Show Cause Commitment A92:
A review of the historical file for Technical Reference Document No. 2A700GP003, " Review of Safety-Related Concrete Structures Including Embedments," has shown that it has been updated periodically to incorporate changes in and results of the concrete verification program.
(Closed) Show Cause Commitment A112:
HL&P/B&R have completed a review of all concrete inspection procedures and applicable training procedures and have issued new procedures to provide assurance that ongoing safety-related concrete work is.neeting all requirements.
(Closed) Show Cause Commitment A113:
The matter of adequate QC staffing to assure that proper preplacement inspections are being conducted, was addressed in the closure of Infraction No. 50-498/79-19-10; 50-499/79-19-10,
" Ineffective Corrective Action to Resolve Previously Identified Concrete Placement Deficiencies." The Infraction was closed in Inspecti;n Report No. 50-498/80-24; 50-499/80-24.
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(Closed) Show Cause Commitment A114:
Revised procedures are now in place and retraining is being performed where necessary.
'(Closed) Show Cause Commitment A115:
Consolidation refresher training is now required every 90 days for consolidation craft.
This item was reviewed in the closure of Infraction No. 50-498/79-15-A; 50-499/79-15-A,
" Failure to Follow Concrete Consolidation Procedure." This is documented
.in Inspection Report No. 50-498/80-24; 50-499/80-24.
3.
Exit Interview The IE inspectors met with licensee representatives tienoted in paragraph 1) at the conclusion of tne inspection on December 18, 1980.
The findings of this inspection were discussed.
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